A group of angels also did not remain in their privileged position near God but left that sphere and so incurred God's wrath. Some interpreters believe Jude alluded here to Genesis 6:1-4 (but cf. Matt. 22:30).33Others believe he was referring to the rebellion of some angels that resulted in Satan's expulsion from heaven. The second explanation seems more probable to me. The apocryphal Book of 1 Enoch described this rebellion that Jude may or may not have had in mind here.34The rebellious angels he referred to are now in bondage and await God's judgment (cf. 2 Peter 2:4). These appear to be different fallen angels from Satan's agents who are at work in the world today, namely, the demons who have considerable freedom.
Jude's point in this illustration was that the apostates in his day had also abandoned a position of great privilege and blessing, namely, the opportunity to serve and glorify God. God would also judge them severely because of their departure. The angels who fell were not elect. Perhaps the apostates in view here were unsaved though God intended them, as well as the Israelites, to be a group for His own possession.
"If the highest beings known in creation were subject to judgment, how much more sinful men!"35